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Beta Public Comment: WCI Essential Requirements of Mandatory Reporting

Beta Analytic submitted a public comment to the Western Climate Initiative relating to the latter’s essential requirements for mandatory reporting final draft. Beta noted that sewage is not 100% biomass.

Thierry Sam Tamers, Beta director, states:

We would like to bring to your attention that there might be a misinterpretation that sewage, as mentioned in the definition of “waste derived fuel,” is entirely from biomass.

Our internal tests using method ASTM D6866 and numerous research publications (two cited below) have demonstrated that sewage contains an important amount of fossil carbon from sources such as detergents, shampoos, etc.

We therefore recommend that the Western Climate Initiative include sewage, along with other materials/fuels that contain fossil carbon, in the sub-category of heterogeneous fuels such as municipal solid waste as cited in the “waste derived fuel” definition.

J. McEvoy and W. Giger, Accumulation of linear alkylbenzenesulphonate surfactants in sewage sludges, Naturwissenschaften, Volume 72, Number 8 / August, 1985, 429-431

http://www.springerlink.com/content/m445654ju0011888/

W Giger, PH Brunner, and C Schaffner, 4-Nonylphenol in sewage sludge: accumulation of toxic metabolites from nonionicsurfactants, Science 10 August 1984, Vol. 225. no. 4662, pp. 623 – 625

http://www.sciencemag.org/cgi/content/abstract/225/4662/623

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3. Beta Public Comment: EPA Renewable Fuel Standard Program
4. [Top Story] EPA Clarifies ASTM D6866 Use in Mandatory GHG Reporting Proposed Revisions